Letter from Paul Georgy, GIB Representative to NFA Boards of Directors
Dear NIBA Members, It is not my intention to be the bearer of bad news, but managing an IB in 2013 will have even more challenges. The impact of Dodd-Frank is trickling down. It will impact us as the CFTC continues to develop new rules, and the NFA must assure they are implemented. A few rules we should all be aware of that will affect how we do business includes the “taping rule” which takes effect on December 21, 2013. This change will impact larger IBs which generate more than $5 million in revenue over 3 years. Another change which affects all of us is the amount of time in which margins calls have to be met before the FCM will receive a capital charge. The old fashion way of sending checks via US Mail may not be quick enough to meet FCM requirements. It may be beneficial to prepare...